ITAR Changes Might Hamper U.S. Parts Exports

PMA manufacturers might have a harder time exporting their civilian aircraft parts due to a new International Traffic in Arms Regulations (ITAR) rule issued by the State Department, according to the Modification and Replacement Parts Association (MARPA). Parts designated as standard and/or integral equipment for civilian aircraft that were previously ITAR-exempt might now fall within the State Department’s jurisdiction if they were approved solely on a non-interference/provisions basis under an FAA type certificate. In other words, a civilian aircraft component approved under an STC/PMA combination based in part on a manufacturer’s “no-technical-objection letter” might not be considered standard and ITAR-exempt equipment. The new rule also says that any part not based on a “civil aviation industry specification [or] standard” is not standard equipment. This new rule could be a nightmare for PMA exporters, according to MARPA, if the State Department claims jurisdiction over all civilian export components not recognized as standard parts. This rule could even affect PMA manufacturers currently selling civilian parts as military replacements to the Defense Department, because these parts are often taken out of the country.